Circuits Assembly Online Magazine - “Be a Manager, Go To Jail”

I don’t usually plagiarize from myself but this case merits an exception. As I wrote in the Aug. 19 issue of our digital newsletter, PCB UPdate, those looking to implement lead-free – more or less all of you – take note. A new standard document stipulates processes for products with hazardous substances.

Although it’s probably flown beneath your radar, the standard could become as ubiquitous as ISO – a standard with which it shares more than a passing similarity.

EIA/ECCB-954 identifies procurement routes, traceability, handling and corrective actions for electronics designers and manufacturers. In many cases, EIA/ECCB-954 stipulates what needs to be documented.

The standard’s full title is a mouthful: “Electrical and Electronic Components and Products Hazardous Substance Free Standard and Requirements.” It was released under the auspices of the Electronics Industries Alliance (eia.org) last March, following an intensive, five-week writing and ratification cycle. (For those who follow such things, that in itself is noteworthy.)

Now, I should take care to point out what the standard does not cover, which is as important as what it does. It does not advise how procurement, design or manufacturing should be performed. It does, however, establish that all those affiliated with the producing of electronics products must understand the regulatory and statutory requirements covering those products, and have processes in place to manage their operations based on their own declaration of how they comply. (Sound familiar?) Further, compliance to EIA/ECCB-954 is based on a company’s own assumptions as to the completeness of its HSF standards.

Steering clear of the technical side of WEEE and RoHS was deliberate, explains Stan Salot Jr., president of the Electronic Components Certification Board (eccb.org) and a coauthor of EIA/ECCB-954. “RoHS lists the technical requirements,” he notes.

Nor does the new standard outlaw HSF. And while it does define requirements for implementing processes to test and analyze any HS content, it doesn’t state what those test procedures are. Says Salot: “The world hasn’t decided how to measure and comply with RoHS. [The standard] doesn’t care how you measure.” Instead, what the standard focuses on is due diligence. “EIA/ECCB-954 says the teams for design, procurement and processing must play together,” he says.

Salot’s explanation is a colloquial way of summing up the standard’s intent. In its introduction, the standard states a “belief that the achievement of HSF products and production processes cannot be realized without an effective integration of management disciplines.”

Companies will comply with EIA/ECCB-954 by ensuring their suppliers are qualified to the “root” of supply. That means, for example, an OEM would audit their suppliers, who in turn would audit theirs, and so on, back to the mines. The OEM wouldn’t have to specifically check their component supplier’s resistor material, but would need to confirm that resistor manufacturer’s documents are in place, Salot says.

The assessment period set forth in the standard is based on a company’s size. An organization with less than 100 employees would undergo two to three days of on-site surveillance followed by one to 1.5 days of record review. A firm with 500 employees would be subject to 5.5 days of on-site visits and three days of records checks.

All that auditing would add up to huge sums of cost and time, of course. Enter third-party audit firms, which will fill that niche much like was done for ISO. One such firm is NSAI Inc. (nsaiinc.com). Lisa Greenleaf, the firm’s U.S. operations manager, concurs that EIA/ECCB-954 is going to “force synergy.” In her view, the standard offers a critical path to establishing a corporate HSF framework. Without it, she says, “The industry will do a kneejerk, ‘How do I comply with WEEE and RoHS?’ ”

Once that part is complete, and a company is registered as in compliance, they become part of the equivalent of a qualified manufacturers list. Certificates are renewed automatically, provided companies stay in compliance with the documentation requirements.

When it comes to EIA/ECCB-954, no function escapes. Sales and marketing, design, supply-chain management and operations are all affected. “Be a manager, go to jail,” warns Salot, his way of saying that the days of blissful ignorance are over, and employees must be ferocious in sharing knowledge. Compliance impacts all functions, and “they better have had to do something, or they didn’t do it right.”

The standard has already made its way to the international level, where the International Electrotechnical Commission (iec.ch) is reviewing it.

It would behoove readers to investigate this important development as it may well become a standard for doing business.